Effective Date: October 24, 2019 Draft Page 1 of 17

Page 1 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

F1 SC&A believes it is important to qualify the use of the 

Vulcan Crucible billing rate against the Board’s five 

surrogate data criteria. SC&A questions the selection of 

Vulcan Crucible and Steel as a data source used to support 

the SEC petition. Although the site was also an AWE that 

processed uranium metal, no rationale is given for why the 

site’s mill-hour billing rate is a reasonable substitute to SSC 

other than this is the site used in the TBD. It is unclear to 

SC&A what the impacts of process conditions, final mill 

product, and mill throughput have on final mill costs. 

Additionally, no information was provided to support the 

selection of this billing rate over other uranium processing 

facilities’ rates. In a cursory search for other facilities’ 

billing rates, SC&A identified Joslyn Manufacturing 

Company had a mill rate of $88 per mill hour in 1948 

(SRDB Ref. ID 11996, PDF p. 131). Use of this billing rate 

would increase the estimated number of mill hours by over 

200 hours and is not bounded by the NIOSH “bounding” 

estimate of 500 hours per year. 

SC&A does note that the SEC bounding assumption of 500 

hours per year is in conflict with the TBD bounding 

assumption of 800 hours per year.

Given that “SC&A concludes that doses to workers 

covered by the SEC petition can be reconstructed in a 

scientifically sound and claimant-favorable manner” 

(SCA-TR-2019-SEC003, p.5), NIOSH proposes that this 

finding be considered a Site Profile issue for tracking 

purposes. 

In the review of the ER for SEC-00247, SC&A states the 

Vulcan Crucible billing rate should be qualified for use in 

Superior Steel Co. exposure assessment. This surrogate 

billing rate is used to determine the number of uranium 

rolling hours in order to establish the occupancy rate, or 

exposure time from uranium rolling. As such, this 

information is used to develop a parameter for use in dose 

reconstruction. Therefore, it is “Type II” surrogate data, 

according to the Board’s 2010 “Criteria for the Use of 

Surrogate Data.” SC&A, in their review, uses the Board’s 

five surrogate data criteria to qualify use of this piece of 

information. Finding 1 is specific to the “Site or Process 

Similarities” criterion and SC&A found no issues with the 

other four criteria in the Board’s document. 

NIOSH agrees with SC&A that the billing rate should be 

reviewed and qualified for applicability to Superior Steel 

Co. NIOSH evaluates surrogate data in accordance with 

five criteria listed in Section 3 of “The Use of Data from 

Other Facilities in the Completion of Dose 

Reconstructions Under the Energy Employees 

Occupational Illness Compensation Program Act” 
Effective Date: October 24, 2019 Draft Page 2 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 2 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

(OCAS-IG-004). It is important to note the Board’s 

criteria are different than NIOSH’s criteria.

To specifically respond to this finding, NIOSH evaluated 

the Vulcan Crucible Billing rate via the 5 criteria in the 

IG: 

1. Source Term

Both Vulcan Crucible and Superior Steel rolled uranium 

billets. The source term, in this sense, is used only to 

determine the metal being processed to justify a 

comparable process for billing purposes. 

Note: the Vulcan Crucible source term is not used to 

determine air concentrations or other exposures at 

Superior Steel Co. 

2. Facility and Process Similarities

This NIOSH criterion is similar to the specific Board 

Criterion discussed in finding 1. 

Vulcan Crucible was performing billet rolling (roughing 

and finishing work) into rods using five rolling machines. 

According to their contract, Vulcan Crucible was to roll at 

least two consecutive weeks out of a five-week period (a 

week is defined as six, nine-hour days) (SRDB 079177). 

Twenty percent of Vulcan Crucible total rolling time was 

AEC contract work (SRDB 006322). Vulcan Crucible 

utilized 25 employees to accomplish their rollings (SRDB 
Effective Date: October 24, 2019 Draft Page 3 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 3 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

006321). Vulcan Crucible’s process involved:

• Uranium metal heated in a furnace; 

• Billets conveyed to roughing roll; 

• Billets passed through roughing roll twice; 

• Rods passed through a finishing roll; 

• Rods dragged to shears, cut and taken back to a 

quenching area for marking and descaling (brushing); 

and

• Rods conveyed to receiving and shipping room. 

The total time to heat and roll one billet was 

approximately 75 minutes (SRDB 008527). 

The Superior Steel process involved: 

• Uranium slab placed into salt bath then into a furnace; 

• Slab craned to roughing mill table; 

• Hot slab passed through roughing mill five times; 

• Slab sent through brushing station; 

• Slab sent to finishing stand; 

• Slab cut to desired dimensions at shear station; and

• Slab rolled for storage or shipping purposes. 

The total time estimate for the sequence is approximately 

one hour. 

Although Vulcan Crucible turned slabs into rods and 

Superior Steel turned slabs into small slabs, these two 
Effective Date: October 24, 2019 Draft Page 4 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 4 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

processes are similar from a billing rate (payment per 

hour) consideration. 

3. Temporal Considerations

The contract that gives Vulcan Crucible’s billing rate is 

dated 1948 and the Superior Steel contract covered 1952 

to 1957. Therefore, they are both in the same era of 

operations. 

Billing rates tend to increase over time; therefore, the 

billing rate in the 1950s would likely be higher than the 

billing rate in the late 1940s. The higher billing rate 

would result in a smaller number of milling hours. 

Therefore, the use of the earlier Vulcan Crucible billing 

rate is considered claimant-favorable.

4. Data Evaluation 

This criterion doesn’t directly apply, as the IG discusses 

review of the quality of exposure data (i.e., “Type I” 

surrogate data as defined in the Board Criteria) and 

monitoring data from Vulcan Crucible is not being used. 

The surrogate data in question is the billing rate. 

Because the data in question is the billing rate, NIOSH 

considers the “data evaluation” criterion to involve 

reviewing other available billing rates. In Finding 1, 

SC&A questioned the choice of the Vulcan Crucible 

billing rate over other facilities’ billing rates and found 

that no information was provided to support that choice. 
Effective Date: October 24, 2019 Draft Page 5 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 5 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

Therefore, the evaluation of this criterion provides a 

response to that part of the Finding. 

Extensive SRDB, OSTI, and Google searches were 

performed for the years 1949 to 1969 with search terms 

“rolling rates, hours milling, pieces per... , “Rolled 

uranium”, “Rolled thorium”, “Rolling uranium”, “Rolling 

thorium” for the following sites:

• Aliquippa Forge 

• Allegheny-Ludlum Steel 

• Bliss & Laughlin Steel

• Brush Beryllium Co (Detroit)

• Carpenter Steel Co

• Fernald

• Hanford

• Joslyn Manufacturing and Supply Co, and

• Simonds Saw and Steel Co 

[Note: NIOSH is still awaiting responses on 3 data 

requests. If additional pertinent information is captured, 

NIOSH will share it with the work group.] These 

searches returned 3 potential billing rates in addition to 

the Vulcan Crucible billing rate.

In 1952, Simonds Saw and Steel had a billing rate of 

$110.53 per rolling hour (SRDB 11996, page 32). The 

number of mill-hours calculated using this billing rate and 

FY1957 payment is comparable to the assumed 500 mill-
Effective Date: October 24, 2019 Draft Page 6 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 6 of 17

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

hours, determined using the Vulcan Crucible billing rate.

In a letter dated February 26, 1948, Joslyn Manufacturing 

was stated as providing a rate of $0.265/pound (SRDB 

11996, page 129) equating to approximately 

$450.00/rolling hour. However, this rate was quoted to 

roll rods from 4.25” round down to approximately 1.5” 

round and it would be imperative that the temperature not 

exceed 650o at any time during the operation. This 

surrogate billing rate was not used due to the different 

processes and controls taking place, which were likely 

driving the cost up. Also note, this higher billing rate 

would have resulted in less exposure hours. 

In their review, SC&A references a billing rate of $88.03 

per hour for Joslyn Manufacturing Company (SRDB Ref. 

ID 11996, PDF p. 131). Further review of the reference 

revealed that this estimate is for the Simonds Company 

mill costs and equates to 11 cents per pound. Simonds 

then indicates that they will consider a possible bid at cost 

+10% or $96.83 per hour. However, Simonds chose not 

to take the work, due to the strict medical and security 

requirements. Therefore, the hourly rate in this reference 

was not implemented. Because this rate was not 

implemented, it is not a good candidate as a surrogate 

billing rate. 

Modification #5 to the Superior Steel contract, effective 

July 1955, was located during a data capture (SRDB 

174312). This contract details an increase in the rolling 
Effective Date: October 24, 2019 Draft Page 7 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 7 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

rate to $1.01 per pound plus details payment rates for 

additional services that may be performed on the slabs: 

(1) $0.030 per pound for inspection after pickling and 

before shipment to heat treating facility, (2) $0.050 per 

pound for inspection of flats before planing, and $0.055 

per pound for Beta treating the slabs. If all additional 

services are provided, the total rate per pound is $1.145. 

5. Review of Bounding Exposure Scenario

Since the surrogate data in question is not exposure data 

(Type I), this criterion doesn’t directly apply. However, 

for this evaluation NIOSH reviewed the conservatism 

included in the calculation of the uranium mill-hours, as 

proposed in the ER, and compared this to other 

information available that can inform the number of millhours. 

The total amount paid to Superior Steel over the contract 

was $356,849 (SRDB 16488). Based on contract 

payments for 1954 through 1957, the highest annual 

payment was $217,246 in FY1956. Data for the 

remaining years indicate payments ranging from $17,658 

(FY 1955) to $54,632 (FY 1957). There is no evidence 

that the production rate in 1956 was different from other 

years. In addition, Modification #5 to the contract (SRDB 

174312) Schedule A shows that Superior Steel Co. was 

approved to receive funds for equipment. Given the dates 

of this contract modification, it is likely these purchases 

would have taken place in 1956, which could explain the 
Effective Date: October 24, 2019 Draft Page 8 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 8 of 17

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

large payment to Superior Steel Co. in that year. 

Using the Vulcan Crucible billing rate of $132 per millhour and the FY1957 payment of $54,632, the number of 

Superior Steel Co. mill hours would be approximately 414 

mill-hours for FY 1957. For the proposed ER approach, 

this number was rounded up to 500 mill-hours of 

exposure to be assumed for all years as a bounding 

assumption for the number of uranium mill rolling hours. 

This equates to 500 hours internal exposure and 500 hours 

external exposure for rolling activities. Additional 

internal exposures are assumed per settling and 

resuspension during non-uranium rolling and additional 

external exposure hours are assumed from contamination 

and during storage of the material and scrap on site (see 

discussion in Observation #3). 

Comparison to Other Available Information 

Rolling Information in Table 7-1 

Table 7-1 in the ER shows, conservatively, there were 16 

rolling days in the approximately 3 years of rolling data 

represented in the table. Doubling this number to account 

for 6 years of work yields 32 rolling days over the 

contract. Assuming 10 hours per rolling day provides a 

total of 320 total hours over the contract or an average of 

approximately 54 hours per year = 6 days per year. 
Effective Date: October 24, 2019 Draft Page 9 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 9 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

Modification #5 to Superior Steel Co. Contract

Modification #5 to the Superior Steel Co. contract, 

effective July 1955, was located during a data capture

(SRDB 174312). This contract details an increase in the

rolling rate to $1.01 per pound plus details payment rates 

for additional services that may be performed on the 

slabs: (1) $0.030 per pound for inspection after pickling 

and before shipment to heat treating facility, (2) $0.050 

per pound for inspection of flats before planing, and 

$0.055 per pound for Beta treating the slabs. If all 

additional services are provided, the total rate per pound 

is $1.145. 

Assuming the amount paid to Superior Steel Co. over the 

entire contract ($356,849) was paid for mill time and that 

only rolling was performed (use the rolling rate of $1.01 

per pound), Superior Steel rolled approximately 353,316 

pounds of uranium. Using the slab weight data available 

in Table 7-1 of the ER, the average slab weights ranged 

from 216 pounds to 599 pounds (overall average of 272 

pounds) and Superior Steel could roll approximately 25-

30 slabs in a day. Using this information and the total 

pounds rolled calculated above, the total number of 

calculated rolling days is approximately 51 days for the 

entire contract. This is substantially lower than the 

current TBD’s 800 hours per year (80 days per year) and 

lower than the proposed 500 hours per year (50 days per 

year) in the ER.
Effective Date: October 24, 2019 Draft Page 10 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 10 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

CONCLUSION

Though the exact Superior Steel Co. contract was located, 

the billing rate is quoted per pound. Unfortunately, there 

is limited information available regarding the typical 

weights per slab or typical weight processed in a day or 

year. Therefore, in order to use the billing rate specific

for Superior Steel Co., additional assumptions regarding 

these variables are required. Given the uncertainty in 

these additional assumptions, that use of these 

assumptions drastically reduces the number of rolling 

hours, and that the Vulcan Crucible billing rate was 

evaluated and qualified as a surrogate (via the review of 

surrogate data above), NIOSH stands by the use of the 

Vulcan Crucible billing rate to determine the uranium 

rolling hours, as proposed. 

Actions and WG 

Discussion: O1

New approach to bounding source term using contract 

billings.

To SC&A’s knowledge, bounding the source term has not 

been done based on contract billing in combination with 

another site’s billing rate in the manner that it is being done 

here. SC&A believes the Board needs to weigh in on the 

acceptability of this use. 

To clarify, NIOSH used the Vulcan Crucible billing rate 

to calculate the number of uranium rolling hours from the 

Superior Steel contract payments. The number of 

uranium rolling hours gives the occupancy rate (i.e., 

exposure time); it is not used to bound the source term. 

The source term for Superior Steel Co. is based on the 

AEC contract (i.e., the initial bid was for uranium rolling) 

and other AEC process documents (e.g., memos regarding 

shipments of material, technical reports). For internal 

dose, the intake rate is calculated based on the air 

sampling results from the HASL air-sampling campaigns 
Effective Date: October 24, 2019 Draft Page 11 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 11 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

performed during four uranium rollings at Superior Steel

Co.. For external dose, the ER proposed to use the 

external dose rate for uranium rolling exposures provided 

in Battelle-TBD-6000. 

As NIOSH sees it, the occupancy rates (i.e., exposure 

time) are determined by the information available for a 

site. The approach taken here is a defensible approach 

because Superior Steel Co. was on a cost-plus-fixed-fee 

contract with AEC, meaning they would have been paid 

based on the work performed. The assumption that the 

entire payment to Superior Steel was made for mill hours 

is claimant-favorable because these payments could 

include equipment upgrades (i.e., documentation shows 

Superior Steel made requests for additional equipment 

from AEC) and other payments (e.g. indirect 

administrative costs and awards of extra compensation) 

not directly related to milling time. However, the 

assumption made is that the entire payment is for milling 

time alone.

Reviewing the rolling information supplied in Table 7-1 

of the ER, there were 16 rolling days in the approximately 

3 years of rolling data represented in the table. Doubling 

this number to account for 6 years of work yields 32 

rolling days over the contract. Assuming 10 hours per 

rolling day provides a total of 320 total hours over the 

contract. See also discussion in Finding 1. Therefore, 

NIOSH upholds that the estimate of 500 rolling hours per 

year is conservative and bounding.
Effective Date: October 24, 2019 Draft Page 12 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 12 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

Actions and WG 

Discussion: F2

SC&A finds insufficient evidence to support splitting the 

data into pre- and post-1955 survey distributions. Evidence 

suggests that the May 1955 sample results may not be 

representative of the typical working air concentrations at the 

site because they represent a theoretically small point in time 

where engineering controls reduced airborne contamination. 

The reductions in air concentrations seen by the introduction 

of man-cooling fans and additional ventilation appear to 

have been largely offset by the introduction of slab brushing 

in the September 1955 survey. Lacking evidence of 

additional engineering controls implemented after the 

introduction of slab brushing, SC&A does not believe that 

limiting the post-1955 distribution to just 1955 data bounds 

potential air concentrations in later years.

Given that “SC&A concludes that doses to workers 

covered by the SEC petition can be reconstructed in a 

scientifically sound and claimant-favorable manner” 

(SCA-TR-2019-SEC003, p. 5), NIOSH proposes that this 

finding be considered a Site Profile issue for tracking 

purposes. 

As this finding states, SC&A found “there was 

insufficient evidence to support splitting the data into preand post-1955 survey distributions.” (SCA-TR-2019-

SEC003, p.14) In addition, “SC&A does not believe that 

limiting post-1955 distribution to just 1955 data bounds 

potential air concentrations in later years.” (SCA-TR2019-SEC003, p. 15) 

On June 21, 2019, NIOSH requested to see the data 

analysis and method used by SC&A for this conclusion. 

NIOSH received and reviewed the SC&A air sample data 

analysis. In reviewing the information provided, NIOSH 

found that SC&A made an error in the development of the 

box plots presented in their ER review. This was 

specifically due to a problem with the default action of the 

function used when a plot is zoomed and resulted in not 

all of the air sampling data being included in their box 

plots. 

Since box plots are only a visual test of whether data 

distributions are similar, ORAUT performed hypothesis 

tests to compare the datasets. A summary of this analysis 
Effective Date: October 24, 2019 Draft Page 13 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 13 of 17

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

is below:

Four sets of air monitoring data were found for Superior 

Steel; 5/13/1953, 8/3/1953, 5/9/1955, and 9/19/1955. In 

each set of raw data values located, a subset in each was 

excluded due to the data not being representative of 

operational data:

• 5/13/1953 – 28 data values were located but five were 

excluded because they were taken during pre-rolling, 

i.e., no slabs were being processed. Four sets of data 

were excluded because they appear to be a reiteration 

of the average values for the finishing areas. 

Therefore, there were 19 samples used from the May 

1955 dataset. 

• 8/3/1953 – 36 data values were found and all are 

considered representative of operational data.

• 5/9/1955 – 61 data values were located but 10 were 

excluded because they were labeled as background 

readings and therefore not considered operational 

data; leaving 51 data values for analysis.

• 9/19/1955 – 46 data values were located but five were 

marked as being taken during lunch and therefore 

were not considered as operational data, leaving 41 

data values for analysis.

This statistical review demonstrated that the May 1955 

dataset is not from the same distribution as the other three 

datasets. Visually it appears lower. Since the data 

doesn’t demonstrate a sustained decrease in air 
Effective Date: October 24, 2019 Draft Page 14 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 14 of 17

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interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

concentrations (i.e., September 1955 is from the same 

distribution as the May and September 1953 dataset) and 

the Superior Steel Co. references don’t provide strong 

evidence engineered controls had been installed prior to 

the May 1955 sampling, NIOSH proposes to remove this 

data from the intake analysis as not representative. 

NIOSH would combine the remaining 3 data sets (i.e., 

May 1953, September 1953, and September 1955) to

determine intake rates that would be applied for the entire 

exposure period. In-line with the approach in TBD-6000, 

separate intake rates would be determined by job title 

(i.e., operator, general laborer, supervisor, and clerical).

Actions and WG 

Discussion: O2

There is a sound basis to use some fraction of the uranium 

concentration as the basis for the thorium concentration; 

however, SC&A notes that use of a one-to-one ratio could be 

important for consistency. This ratio is considerably more 

claimant favorable than the 10 percent assumption. The 

approach used here could establish a precedent that might 

require NIOSH to revisit previous ERs that use a lower ratio. 

For the reasons noted in finding 1, SC&A does not support 

isolating the 1955 HASL studies from the 1953 studies. 

SC&A notes that resolution of that issue will have a direct 

impact on the thorium internal dose reconstruction. 

NIOSH disagrees that the approach used for Superior 

Steel is inconsistent with the approach used at other sites. 

In the case of Bridgeport Brass, the 10% ratio is applied 

because both uranium and thorium were being processed 

at the same time (i.e., milling time is assumed to be 

overlapping). See page 13 of ORAUT-TKBS-0030 Rev 

02 for a discussion of the determination of the 10% by 

mass, and Tables 3-6 and 3-8 for the applicable date 

ranges for the uranium and thorium intakes respectively. 

The Bridgeport Brass air mass load is being divided based 

on the total mass of uranium and thorium material that 

was concurrently processed during a given time. This 

approach can be thought of as splitting or proportioning 

the alpha result for the air sample based on the proportion 
Effective Date: October 24, 2019 Draft Page 15 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 15 of 17

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

of thorium work to uranium work. This would need to be 

done because the air sampler would have been running 

during both thorium rolling and uranium rolling activities. 

Therefore, the total alpha result for the air sample would 

represent concurrent thorium and uranium intakes. Note 

the typical alpha analysis performed on air samples would 

not be able to distinguish the thorium from uranium 

directly to report these separately.

In the case of Superior Steel, the uranium and thorium 

metals were processed during separate periods (i.e., 

thorium rolling was not performed during the HASL airsampling campaigns, only uranium rolling occurred). 

Therefore, the air sample alpha result is only due to 

uranium contamination.

The proposed Superior Steel approach assumes that the 

generation rate of airborne contamination (and therefore 

the air sample mass load) calculated from the HASL air 

sample results from uranium rollings at Superior Steel is 

applicable to thorium rollings at Superior Steel. The air 

mass load for uranium is assumed to be the same for the 

thorium operations because it was stated that Superior 

Steel would use the same procedures (SRDB 75651, 

License No. C-3480). 

Note: This same assumption (i.e., that the uranium 

airborne contamination generation rate during milling is 

the same as the thorium airborne contamination 

generation rate during milling) is applied in the 
Effective Date: October 24, 2019 Draft Page 16 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 16 of 17

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

Bridgeport Brass approach, but is not directly stated as so.

Actions and WG 

Discussion: O3

SC&A finds this storage time assumption to be inadequate to 

capture the length of time material was likely found on site. 

If the site milled uranium metals for 500 hours per year, then 

it is reasonable to assume 10-hour milling once per week. 

For the 250 pre-rolling and 250 post-rolling hours, 

assumption to hold true, uranium metals would have to 

arrive on the day before rolling and be shipped off-site the 

day following rolling. Table 7-1 in the NIOSH SEC ER 

shows that the site regularly had more than a single day's 

rolling in inventory. Additionally, during the April 2019 

Board meeting, the petitioner indicated that scrap material 

was stored on-site for extended periods of time post rolling.

In light of the April 2019 ABRWH petitioners’ comments

and additional review of applicable reference documents, 

NIOSH has re-evaluated the amount of onsite storage 

time associated with the uranium source materials and 

scrap metal. 

NIOSH proposes to change the exposure time

assumptions for stored material from 500 hours per year 

to year-round, minus rolling time, for the entire 

operational period (i.e., from June 1952 through the end 

of the contract in November 1957). 

Actions and WG 

Discussion: O4

Despite the claimant favorability of the assumption, SC&A 

questions the decision to assume annual medical 

examinations in spite of a lack of evidence. In recent years, 

the Board has made a concerted effort to improve 

consistency between sites. It is unclear if all AWE sites with 

no evidence of examinations receive the same claimantfavorable assumptions. 

For occupational medical X-ray dose reconstruction, 

NIOSH uses the guidance provided by ORAUT-OTIB0006 Rev. 05, Dose Reconstruction from Occupational 

Medical X-Ray Procedures, which provides default 

assumptions when evidence is lacking. With regards to 

chest X-rays, ORAUT-OTIB-0006 states, “In the 

complete absence of information about a site’s chest Xray screening protocol and standard projections (including 

the lack of X-ray records in the claim files), a preemployment, annual, and termination PA radiographic 

chest X-ray should be assumed” (p. 25). Therefore, with 

a lack of X-ray protocol information and a lack of X-ray 

records in the claimant files for the Superior Steel Co., 
Effective Date: October 24, 2019 Draft Page 17 of 17

Superior Steel Co. Special Exposure Cohort (SEC-00247) Issues Matrix

Page 17 of 17

This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, 

interim, and White Paper documents are not final NIOSH or ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary positions taken on 

technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC §552a and has been cleared for 

distribution. 

Finding / 

Observation No. Issue Identified by SC&A NIOSH Response

this default applies.

An additional consideration for whether to assign 

occupational medical dose is the physical location of 

where the X-ray examination occurred. To determine the 

location where the X-rays were performed, NIOSH uses 

the guidance provided by ORAUT-OTIB-0079 Rev. 02, 

Guidance on Assigning Occupational X-Ray Dose Under 

EEOICPA for X-Rays Administered Off-Site, which states 

that when neither historical documentation nor claim file 

records provide information about where the occupational 

X-rays were taken, dose reconstructors should assume 

occupational medical X-ray exposure occurred at the 

covered facility where the energy employee worked. 

Therefore, with a lack of evidence regarding where Xrays were taken, the default assumption that occupational 

medical X-rays occurred on-site is applied for Superior 

Steel Co. 

NIOSH welcomes examples from SC&A regarding its 

inconsistent application of this guidance for other AWE 

sites.